Last Updated: May 2018
- 1.1. 137 Pillars Group, including our affiliates, use your personal information in order to fulfil our commitment to providing you an unparalleled guest service experience in connection with all of our guest interactions. As part of that undertaking, we are committed to safeguarding the privacy of the personal information that we hold.
- 1.3. The terms “we”, “us” and “our” refer to 137 Pillars Group;
- 1.4. The terms “you”, “your” and “guest” refer to you;
2. Personal Information
- 2.1. Personal Information that we may collect about you is directly related to an individual and the type of information includes:
- 2.1.1 Your name;
- 2.1.2. Postal or Billing address;
- 2.1.3. Email address;
- 2.1.4. Telephone, Mobile or Fax number;
- 2.1.5. Payment information;
- 2.1.6. Identification (e.g. passport or ID card details);
- 2.1.7. Location being used;
- 2.1.8. Device being used;
- 2.1.9. Cookies and similar technologies;
- 2.1.10. Hotel stay information;
- 2.1.11. Your Preferences;
3. Use of Personal Information
- 3.1. In order to access certain features, content or functions of the services, for example, account registration and reservations, you may be asked to provide personal information such as your name, surname, phone number, date and place of birth, gender, residing address, e-mail address, work contact details, business title, nationality, passport, visa information, profile picture and other personal information.
- 3.2. Guest information will be recorded in our systems for the hotels where you have stayed, the dates of arrival and departure, any special requests made and notes regarding your service preference.
- 3.3. If you are an employee of a corporate account, vendor or other type of business partner, you must provide us the details of employer and/or other relevant details to ensure that you are eligible to use the relevant services.
- 3.4. When you purchase products and services from us, your payment information from credit, debit or other card types, including card number, expiration date and address may be collected by us and/or third-party payment processors.
- 3.5. Information that you provide us directly or indirectly can be through, for example, surveys and other promotions relating to our services, interaction with customer service and signing up to receive newsletters and other services and/or third-party products or services.
- 3.6. Your Information helps us to provide you with a better or more personalised level of service, including information and services from a third party;
- 3.7. Your Personal Information may also be used to:
- 3.7.1. provide and charge for hotel accommodation and other goods and services;
- 3.7.2. respond to your requests for information and services including services from a third party;
- 3.7.3. fulfil contractual obligations to you, anyone involved in the process of making your travel arrangements such as travel agents, group travel organisation, your employer and vendors;
- 3.7.4. conduct market research, customer satisfaction and quality surveys, and direct marketing and sales promotions;
- 3.7.5. administer general record keeping;
- 3.7.6. meet legal and regulatory requirements;
- 3.7.7. test and evaluate new products and services;
- 3.7.8. send you marketing, promotional, emails, message and other correspondence and notifications regarding the services and the services of third party we believe that may be of interest to you;
- 3.7.9. assist with the detection and prevention of fraud or infringement of our or and/or any third party’s rights;
- 3.7.10. establish and maintain a responsible commercial relationship with you and to provide ongoing service;
- 3.7.11. respond to your questions, complaints, or reviews of our product or services or those of other member hotels;
- 3.7.12. enable our advertisers, where appropriate, to provide you with more personalised content, and track the effectiveness of certain advertising campaigns;
- 3.8.1. Under applicable law including laws outside your country of residence;
- 3.8.2. To comply with legal process;
- 3.8.3. To respond to requests from public and government authorities, including public and government authorities outside your country of residence;
- 3.8.4. To enforce other terms and conditions;
- 3.8.5. To protect our operations or those of any of our affiliates;
- 3.8.6. To protect our rights, privacy, safety or property and/or that of our affiliates, you or others;
- 3.8.7. To allow us to pursue available remedies or limit damages that we may sustain.
- 3.9. In addition, our services may include features that rely on the use of information stored on, or made available through, your mobile device. We may also ask to collect or use the specific location of your mobile device for example accessing your device GPS. If you agree to allow access to your location, you agree that we and our service provider may collect such location-based information from your device.
- 3.10. We may also collect other information based on your location and your device’s proximity to “beacons” and other similar proximity systems, including, for example, the strength of the signal between the “beacon” and your device and the duration that your device is near the “beacon”.
- 3.11. The type of location data we collect depends on a number of factors, including the type of device you are using for example laptop, smart phone, tablet and the type of connection enable on your device for example wi-fi, Bluetooth, broadband cable.
- 3.12. We may use third party services to provide mapping services that will request access to your location information.
- 3.13. If you access a service via a third-party platform account, for example, logging into a hotel booking system platform, we may collect certain personal information from the third-party platform, such as your user name and other information you provided to the third-party platform in connection with your account.
- 3.14. You may have the ability to communicate with other users and post comments or otherwise interact with us through services that are available to the public and/or other users (e.g. posting on Facebook). We may collect any information you submit, post or provide in the course of such activities.
4. Disclosure of your personal information
- 4.1. Your personal information may be disclosed in connection with services that we provide.
- 4.2. Personal information may be shared within our company so that we can better provide services to you.
- 4.3. Limited personal information will be shared with third-parties involved in supplying guest services that guests have purchased to the extent necessary for the third-party to provide the service.
- 4.4. Personal information may be shared with third-parties retained by us to perform functions on our behalf such as reservation handling, data processing or storage, guest surveys and/or research.
- 4.5. We retain your personal information including details of your stay, preferences, room/accommodation type and amenities used after your stay and this will not be sold or transferred to any party not involved with your stay with us. We may disclose your personal information to an authorised licensee in connection with the services, including with respect to a reservation your book through us, in connection with offerings of travel related services or to our developers, or to enable an authorised licensee to market and operate the business that its licensed.
5. Use of Aggregate Information
- 5.1. Aggregated information is the consolidation of data relating to multiple people and cannot be directly related to any one person.
- 5.2. We may use a variety of third party advertising networks, data exchanges, traffic measurement service providers marketing analytics service providers and other third parties (collectively, “Third-party advertising service providers”) to, for example, serve advertisements based on our services, facilitate targeting of advertisements based on your location and aggregated data and services and platforms you have visited or used.
- 5.3. Such Third-party advertising service providers also enable us to, among other things, help deliver advertisements and/or other content to you for products and services that you might be interested in and to conduct research regarding the usefulness of certain advertisements to you.
- 5.5. Much of the personal information we process is information that you or someone acting on your behalf knowingly provides to us. However, in other instances we process personal information that we are able to infer about your based on other information you provide to us or during our interactions with you, or personal information about you that we receive from a third party. This policy also applies to the personal information about you that we receive from a third-party, unless specifically covered by such third-party’s policy.
- 5.6. In addition, we may receive your personal information from public databases, joint marketing partners and other third party such as your travel agent airline, credit card, social media platform.
6. Online Usage data and technical information
- 6.1. The services we may use include features that automatically collect certain information, which may include the unique device identifier assigned to your device, third party platform anonymous identifiers, and other information regarding your use of the services.
- 6.2. This information assists us in authenticating your usage and/or device, keeping track of your preferences, creating a more tailored user experience and better serving your particular interested and needs.
- 6.3. The services and/or third parties may use “cookies” which are small data files containing information about you that is storage on your hard drive, “embedded scrip”, “pixel tags” and other similar tracking technologies (collectively, “tracking technologies”) to collect information automatically as you interest with the services.
- 6.4. Such information may include “clickstream” data, the domain name of the service providing you with internet access, your device type and attributes, internet protocol (IP) address, network connection type for example wi-fi, 3G, LTE, browser type and version, operating system and platform, average time spent on the services, pages viewed, content searched for, access time and other relevant statistics, and your interactions with playlists, audio visual content, other users of the services, advertising, and products, and services which are offered, linked to or made available on or through the services.
- 6.5. Such information may be collected by us and/or our third-party service providers and partners. Certain tracking technologies enable us to customise your experience on the services and provided tailored recommendations, promotions, advertisement and other content relating to your specific interests. Other tracking technologies are used to make login to the services earlier such as by remembering your user id and allow us to collect none specific location information.
7. Corporate reorganization/restructuring/co-branded
- 7.1. We may disclose your personal information to a third party in the event of any reorganisation, restructuring and/or co-branding.
- 7.2. We may offer co-branded services and features, such as activities, events, initiatives, promotions and selected products, services provided by us and/or our affiliates entities or other third-party partners and that may be made available on the services and/or our co-branded partner’s platform, website or service.
8. Security of use of your personal information
- 8.1. We understand that the security of personal information is important to you and to us, therefore, we use software that encrypt your personal information that you provide to us.
- 8.2. The personal information that we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronics access control, firewall technology and other reasonable security measures. However, the security systems cannot prevent 100% of all loss, misuse or alteration of personal information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law.
- 8.3. If you have reason to believe that your information with us is no longer secure, please notify us immediately in accordance with the “Contact us” or to the Information Officer at the address in Section 9.
9. Change or update your personal information
- 9.1. If you would like or need to change and/or update your personal information that you have provided to us, you may contact us via:
Attention to: Information Officer
Address: 137 Pillars Hotels and Resorts,
38 Sukhumvit Soi 39,
Bangkok 10110, Thailand
10. Retention of your information
- 10.2. We will delete personal information when it is no longer needed and/or take proper steps so that you can no longer be identified from it unless we need to keep your information to comply with legal or regulatory obligations to which we are subject to.
- 10.3. In any event, upon expiration of the maximum storage term set forth by applicable law.
11. Use of service by children
- 11.1. We do not sell products and/or services to individual under the age of 16 years,
- 11.2. Where the child is below the age of 16 years, such processing shall be lawful only if and to the extent that consent is given or authorised by the holder of parental responsibility over the child.
12. Updates to this privacy statement
- 12.1. We may change this privacy statement. The “LAST UPDATED” legend at the top of this page indicates when this privacy statement was last revised. Any change will become effective when we post the revised privacy statement on the Online Services. Your use of the Services following these changes means that you accept the revised privacy statement.
13. Contacting us
- 13.1. If you have any questions about this privacy statement, please contact us at firstname.lastname@example.org, or mailing address as set out below:
Address: 137 Pillars Hotels and Resorts
38 Sukhumvit Soi 39,
Bangkok 10110, Thailand
- 13.2. Please do not include credit card or other sensitive information in your e-mail to us for your security.